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at 120 21. The Court ruled that New York's "Son of Sam" law was inconsistent with the First Amendment because it was "overinclusive" in that it "reaches a wide range of literature that does not enable a criminal to profit from his crime while a victim remains uncompensated. " 502 U. S. at 121 22. Although the holding in Simon and Schuster was explicitly limited to New York's "Son of Sam" law, the decision appears to leave little doubt, if any, about the unconstitutionality of 18 U. S. C. In light of Simon and Schuster, some courts have relied on restitution orders and fines where convicted defendants appeared likely to receive proceeds from the sale of their stories about their crimes. See United States v. Jackson, 978 F.